E
SUB-COMMITTEE ON FIRE PROTECTION
56th session
Agenda item 22
FP 56/INF.8
2 November 2012
ENGLISH ONLY
DEVELOPMENT OF INTERPRETATION OF SOLAS REGULATION II-2/13.6
ON MEANS OF ESCAPE FROM RO-RO SPACES
Report on studies on practical application of the regulation in support of
interpretation of requirements
Submitted by the Republic of Korea
SUMMARY
Executive summary:
This document provides information regarding practical application
of SOLAS regulation II-2/13.6 in shipyards and shipping companies
in order to facilitate the development of clarification on the
regulation through findings from studies on the actual application
Strategic direction:
5.2
High-level action:
5.2.1
Planned output:
5.2.1.32
Action to be taken:
Paragraph 6
Related documents:
MSC 90/25/16 and MSC/Circ.1120
Introduction
1
At MSC 90, Sweden submitted document MSC 90/25/16 which proposed to include
an unplanned output on the development of an interpretation of SOLAS regulation II-2/13.6
on means of escape from ro-ro spaces in the work programme of the Sub-Committee on Fire
Protection.
2
According to the requirements, a few vague expressions can be seen as follows:
.1
the term "normally employed" has no specific interpretation in any IMO
document;
.2
the term "safe escape" could bring a wide variety of understandings and
interpretations; and
.3
the term "at the fore and aft ends of the space" does not provide the clear
location of the escape routes.
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3
In light of the possibility that different Administrations have different interpretations
on these requirements, this could lead to differences in application and potentially different
levels of safety on different ships.
4
In the context of this matter, the Republic of Korea submitted this document
containing a report of studies on the practical application of SOLAS regulation II-2/13.6 which
were conducted among some shipyards in Korea and shipping companies operating ro-ro
cargo ships such as PCTCs and PCCs, as set out in the annex.
5
The Republic of Korea hopes that this document is of assistance in consideration of
clarification of requirements.
Action requested of the Sub-Committee
6
The Sub-Committee is invited to note the information provided in this document in
order to help the development of interpretations of SOLAS regulation II-2/13.6 on means of
escape from ro-ro spaces and take action as appropriate.
***
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Annex, page 1
ANNEX
REPORT ON STUDIES ON PRACTICAL APPLICATION OF THE REGULATION IN
SUPPORT OF INTERPRETATION OF REQUIREMENTS
Practical application of SOLAS regulation II-2/13.6
1
SOLAS regulation II-2/13.6 states that:
"At least two means of escape shall be provided in ro-ro spaces where the crew are
normally employed. The escape routes shall provide a safe escape to the lifeboat and
liferaft embarkation decks and shall be located at the fore and aft ends of the space."
2
SOLAS regulation II-2/3.41 states that:
"Ro-ro spaces are spaces not normally subdivided in any way and normally
extending to either a substantial length or the entire length of the ship in which motor
vehicles with fuel in their tanks for their own propulsion and/or goods (packaged or
in bulk, in or on rail or road cars, vehicles (including road or rail tankers), trailers,
containers, pallets, demountable tanks or in or on similar stowage units or other
receptacles) can be loaded and unloaded normally in a horizontal direction."
3
Certain shipbuilder raised the question as to whether ro-ro spaces are spaces the
crews are normally employed. However, based on vessel operation manuals explaining
crew's job descriptions from shipping companies and actual features of crew's routine work
performed on board the ships, it apparently shows that the crews are conducting their normal
jobs on ro-ro spaces. As pointed out in the document submitted by Sweden (MSC 90/25/16),
this could for instance include loading and unloading cargo, inspection of cargo whilst at sea,
sounding of tanks, cargo deck cleaning, check of fire-fighting appliances, etc. Thus, it is
considered that the crew are routinely employed on ro-ro spaces where cargo is stored.
4
In addition to that, a few questions arise as to whether "the escape routes" provide a
safe escape. According to findings on practical application of ro-ro cargo ships being built
and existing ro-ro cargo ships, the escape routes between ro-ro spaces of the lowest car
deck and lifeboat or liferaft decks do not run through directly. In other words, the escape
routes are disconnected in the middle way without further means of escape on certain car
decks and the crew must move along the car decks in order to reach access for the next
level. The distance to walk to escape is ranged from several meters to dozens meters.
5
The escape routes at the fore end of the space on most of ships consist of
non-enclosed and non-insulated vertical ladders as means of escape. As for escape routes
at the aft end of the space, ro-ro spaces on the upper car decks are horizontally accessible
to means of escape from machinery spaces on the same deck. However, it was observed
that ro-ro spaces on the lower car decks, which were equipped with vertical ladders, are
inaccessible to means of escape from machinery spaces.
6
Also, it does not seem that the vertical ladders that are non-enclosed or
non-insulated properly protect the crews from blaze or smoke, which might causes
casualties.
7
It could cause a problem when ro-ro cargo ships are fully loaded with cargo.
Generally safety distance between two adjacent automobiles on ro-ro spaces is set less
than 1 metre and the heights of the majority of car decks are observed less than 2.5 metres.
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Annex, page 2
It is quite difficult for the crew to manoeuvre through the automobiles to have access to the
escape routes. The crew who are familiar with ships' structures could even face some
difficulties in escaping while being caused at least some time delays.
8
Large ro-ro cargo ships have more than 10 car decks below the lifeboat or liferaft
decks. If only vertical ladders are installed as safe means of escape, it would probably
require tremendous physical efforts to climb the ladders to the top.
9
Normally, the frequency of entering ro-ro spaces on the lowest car deck is not low
once the inspection of cargo, check of fire-fighting appliances, sounding of ballast water
tanks, ullaging of bunker tanks and deck cleaning etc. are being routinely conducted on ro-ro
spaces.
10
The term "at the fore and aft ends of the space" does not imply clear meaning. A few
shipyards follow an interpretation that it is considered as installed "at the fore and aft ends of
the space" if means of escape from a ro-ro space is installed in the area within the distance
equal to the breadth of the cargo space from the most forward and aftermost point of the
cargo space. However, some ro-ro spaces are equipped with the escape routes outside the
above-mentioned area.
A fire on a vessel in 2001
11
In 2001, a vessel (Pure Car/Truck Carrier) operated by Korean shipping company
suffered from a fire which caused serious damages to No.9 and No.10 car decks and
adjacent hull and machinery etc. including about more than 3,000 vehicles, which fortunately
there was no loss of human lives. As it can be seen from the pictures below, if a fire which
breaks out on ro-ro spaces could lead to terrible incidents due to thousands of motor vehicles
with fuel in their tanks demonstrating that current means of escape are not good enough to
provide a safe escape in case of fire.
Figure 1 – Damages to No. 9 Deck and its cargo
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Annex, page 3
Figure 2 – Fire damages viewed from outside
Conclusion
12
In summary, means of escape from ro-ro spaces are not uniformly installed in
respect of structural features unlike those from machinery spaces or on passenger ships.
13
Certain escape routes do not provide continuous access to lifeboat or liferaft decks
from ro-ro spaces on some cargo decks, which are not properly protected from a fire either.
14
Sometimes, means of escape at the fore or aft end of the space are not located
within the fore or aft end of the space.
15
It is recommended that further consideration with regard to the above matters is
needed to clearly interpret the requirements on means of escape from ro-ro spaces.
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